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FAQEU

DMA FAQ Core platform services

Core platform services are the DMA service categories that can trigger gatekeeper designation and anchor Articles 5 to 7 obligations.

This FAQ helps map a product to the DMA service categories, separate one core platform service from another, and preserve evidence for designation and Article 11 reporting.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 26, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 26, 2026
Overview

Under the EU Digital Markets Act, a is one of the ten categories listed in Article 2(2). A product does not become subject to gatekeeper obligations merely because it fits a category: the Commission must designate the undertaking and list the relevant service in the . Start with category and service-boundary mapping, then check user thresholds, designation status, and service-specific compliance evidence.

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4 of 4 questions
Question 1

What counts as a core platform service under the DMA?

Article 2(2) lists ten categories: online intermediation services, online search engines, online social networking services, video-sharing platform services, number-independent interpersonal communications services, operating systems, web browsers, virtual assistants, cloud computing services, and online advertising services provided by an undertaking that also provides another listed core platform service. Software application stores are included within online intermediation services; they are not an eleventh category.

A service-scope answer should name the category, explain the product boundary, and identify whether the Commission has listed that service in a gatekeeper . The label used in a product roadmap is not enough; the DMA analysis turns on the Article 2 category and the service that is an important gateway for business users to reach end users.

  • Map the product to one Article 2 category before applying Articles 5 to 7 obligations.
  • Treat advertising separately only where the DMA online-advertising category is supported by the undertaking's other core platform services.
  • Do not collapse integrated products automatically; the Annex says services may be distinct where they are in different categories or used for different purposes.
  • Do not split a service mainly by country-code domain, generic domain, or geographic attribute when calculating active users.

Is every platform feature a DMA ?

No. A feature is relevant to analysis only if it falls within an Article 2(2) category and forms part of the service boundary being assessed. Articles 5 to 7 apply only after the Commission designates the undertaking and lists the service. Record the category, product boundary, user purpose, active-user method, and instead of treating every feature or product of a gatekeeper as covered.

Citations
Question 2

Which evidence supports a DMA gatekeeper designation assessment?

Article 3 designates an undertaking as a gatekeeper when it has significant impact on the internal market, provides a that is an important gateway for business users to reach end users, and has an entrenched and durable position or is expected to have one soon. The quantitative presumption uses business-size evidence plus service-level user evidence.

For the user-gateway presumption, the DMA threshold is at least 45 million monthly established or located in the Union and at least 10,000 yearly established in the Union for the in the last financial year. The same user thresholds must have been met in each of the last three financial years for the entrenched-and-durable-position presumption. The Annex requires unique users to be counted once for the relevant service and period: monthly for active end users and yearly for active business users.

  • Keep the undertaking-level evidence for Union turnover, market capitalisation, or equivalent fair market value and the Member States where the same service is provided.
  • Keep service-level active end-user and active business-user counts with the Annex methodology used for that category.
  • Document duplicate-risk controls for users across devices, platforms, accounts, logged-in and non-logged-in environments.
  • Preserve the notification or designation record for each that meets the Article 3 thresholds.
  • If a service meets the thresholds but the undertaking argues the presumption should not apply, keep the substantiated rebuttal arguments and Commission response.

What thresholds matter for DMA scoping?

The service-level gateway threshold is at least 45 million monthly established or located in the Union and 10,000 yearly established in the Union in the last financial year. The same user thresholds must be met in each of the last three financial years for the durability presumption. The undertaking-level financial and three-Member-State test also matters, and the Commission can designate an undertaking under the qualitative Article 3 process even when every quantitative threshold is not met.

Citations
Question 3

How should teams scope one core platform service versus another?

The DMA Annex is the most useful scoping control because it explains how and are identified for each category. It also gives boundary rules: services in the same category should not be split mainly by domain name or geography, while services used for different purposes can be treated as distinct even when users overlap.

A good scoping file therefore separates category, user purpose, business-user route to end users, metrics, and designation status. It should also name category-specific counting logic: for example, search uses queries and indexed business websites, operating systems use activated or used devices and developers, and online advertising uses advertisement-impression and advertiser or intermediary interactions.

  • State whether the service is online intermediation, search, social networking, video sharing, messaging, operating system, browser, virtual assistant, cloud computing, or online advertising.
  • Describe end-user activity used for the count, such as login, query, content play, communication, device use, browser address entry, assistant activation, cloud use, or ad impression.
  • Describe business-user activity used for the count, such as listings, transactions, indexed business websites, business accounts, uploaded content, business communications, developer activity, hosted cloud services, or advertiser and publisher interactions.
  • Explain why overlapping users do or do not create one service boundary.
  • Record any renamed, bundled, split, or newly launched service because Article 4 allows designation decisions to be reconsidered, amended, or repealed when facts substantially change.

Can a bundled product contain more than one DMA ?

Yes. The Annex says integrated services can still be distinct when they are in different Article 2 categories or are used for different purposes by end users or business users. A bundle may therefore require separate service boundaries, active-user counts, obligation mapping, and Article 11 annexes.

Citations
Question 4

What are the Article 11 reporting implications?

Article 11 reporting is organised by designated and applicable obligation. The Commission template says each designated gatekeeper must provide a compliance report within 6 months after designation, update it at least annually, and provide separate standalone annexes for each core platform service for which it has been designated.

For each and each applicable Articles 5 to 7 obligation, the template asks for a compliance statement, an exhaustive explanation of measures, supporting data and internal documents, implementation timing, product and geographic scope, technical and engineering changes, customer-experience changes, remuneration and terms changes, consultation with users or interested parties, testing and indicators, monitoring systems, and feedback from business users or end users.

  • Build one evidence bundle per designated , not one generic DMA bundle for the undertaking.
  • Map each Articles 5 to 7 obligation to the service and explain any obligation that cannot by nature apply to that service.
  • Keep raw data and calculation explanations ready for Commission requests.
  • Preserve redlines or change summaries for annual report updates.
  • Track the top business-user information requested by the template for each .

Why does scoping matter for Article 11?

The Commission's Article 11 template expects a separate standalone annex for each designated and information for each applicable Articles 5 to 7 obligation. A wrong service boundary can therefore produce missing evidence, overbroad claims, or obligations mapped to the wrong product.

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Recommended next step

Prepare core platform service evidence before Article 11 reporting

Use the cited sources listed here to verify obligations and the supporting evidence requirements.

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Open Research Copilot for the DMA

Ask cited questions about core platform service scope, gatekeeper designation, thresholds, and Article 11 reporting.

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Talk through DMA scoping

Review core platform service boundaries, evidence gaps, and reporting implications with Sorena.

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Primary sources

References and citations

European Commission - DMA gatekeepers
digital-markets-act.ec.europa.eu
Referenced sections
  • Current Commission portal with designation decisions and case links for listed gatekeepers and core platform services.
"currently designated"
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